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Category:AFFIDAVITS
MONTHYEARML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20237A0631998-08-0606 August 1998 Affidavit of TC Feigenbaum Re Length of Fuel Cycles at Seabrook Station & of Future Plans for Fuel Cycle Length. W/Certificate of Svc ML20236M5181998-06-27027 June 1998 Affidavit.* Affidavit of J Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4871998-06-27027 June 1998 Affidavit.* Affidavit of K Conrad Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5091998-06-27027 June 1998 Affidavit.* Affidavit of Sn Haberman Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5231998-06-27027 June 1998 Affidavit.* Affidavit of SA Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4971998-06-27027 June 1998 Affidavit.* Affidavit of D Bogen Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5061998-06-27027 June 1998 Affidavit.* Affidavit of C Nord Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5401998-06-27027 June 1998 Affidavit.* Affidavit of Eh Mecklejohn Re 980506 License Exemption Request from Operator of Seabrook Station ML20216E0351998-04-13013 April 1998 Affidavit of FW Getman (Great Bay Power Corp) Requesting That NRC Withhold Util Response to NRC RAI Re Proposed Acceleration of Decommissioning Funding for Ownership Share of Seabrook Station ML20140B9711997-06-0404 June 1997 Affidavit of FW Getman Per 10CFR2.790,re Great Bay Power Corp'S Filing of Suppl to Petition for Partial Reconsideration of Exemption Order ML20073E1641991-04-19019 April 1991 Affidavit of J Hausner.* Discusses Facility Offsite Radiological Emergency Planning.W/Certificate of Svc ML20065K3421990-11-0202 November 1990 Affidavit of Cole.* Discusses Issue of Whether Commonwealth of Ma School Teachers & Day Care Ctr Personnel Perform Roles Contemplated in Spmc ML20065K3451990-11-0101 November 1990 Affidavit of Mc Sinclair.* Responds to Questions Posed by Aslab in ALAB-937 Re Whether Spmc Provides Adequate Supervision & Care of Children Evacuated to School Host Facility at Holy Cross College.W/Certificate of Svc ML20062C2781990-10-19019 October 1990 Affidavit of a Callendrello Addressing Issue Re Staffing of Seabrook Plan for Massachusetts Communities School Host Facility as Discussed in Aslab 900918 Decision.W/Certificate of Svc ML20062C2651990-10-18018 October 1990 Affidavit of Ds Mileti Addressing Issue Whether Massachusetts School Teachers & Day Care Ctr Personnel Would Respond to Assignments in Emergency to Escort Children on Buses ML20059M6201990-09-24024 September 1990 Affidavit of GL Iverson.* Responds to Statements Made in Mc Sinclair 900907 Supplemental Affidavit.W/Certificate of Svc ML20059B0021990-08-22022 August 1990 Affidavit of RW Donovan Re Staffing Adequacy for Implementation of New Hampshire Radiological Emergency Response Plan for Plant.W/Certificate of Svc ML20059A9981990-08-21021 August 1990 Affidavit of Jc Dolan Re Adequacy of Staffing for Implementation of New Hampshire Radiological Emergency Response Plan for Plant ML20059B0281990-08-21021 August 1990 Affidavit of GL Iverson Re Position of Governor Media Ctr representative.Twenty-second Initial Vacancy Was New Hampshire Public Utils Commission Lead Engineer ML20059A8911990-08-16016 August 1990 Affidavit of GL Iverson Re Adequate Staffing at New Hampshire Radiological Emergency Plan in Event of Radiological Emergency at Seabrook.W/Certificate of Svc ML20056B2251990-08-0606 August 1990 Affidavit of Mc Sinclair.* Affidavit Re Offsite Radiological Emergency Response Planning for State of Nh & Spmc ML20081E2431990-07-31031 July 1990 Affidavit of a Desrosiers Re Evacuation of Advanced Life Support Patients ML20081E2471990-07-31031 July 1990 Affidavit of B Cohen Re Evacuation of Advanced Life Support Patients ML20081E2401990-07-31031 July 1990 Affidavit of Rl Goble Re Preparation of Advanced Life Support Patients for Evacuation ML20081E2511990-07-31031 July 1990 Affidavit of Sj Plodzik Re Evacuation of Advanced Life Support Patients ML20055G6521990-07-11011 July 1990 Affidavit of T Urbanik Re Licensee Motion for Summary Disposition of Advanced Life Support Patients Issue.* Addresses Issues Re Preparation of Advanced Life Support Patients.W/Certificate of Svc ML20058K8011990-06-25025 June 1990 Affidavit of Am Callendrello.* Addresses Issues Defined by ASLB in LBP-90-12 Re Preparation of Advanced Life Support Patients for Evacuation & Impact on Special Population Evacuation Time Estimates.W/Certificate of Svc ML20058K7811990-06-25025 June 1990 Affidavit of J Bonds.* Addresses Issues Defined by ASLB in LBP-90-12 Re Advanced Life Support Patients & Consideration of Preparation Time for Evacuation Under State of Nh Radiological Emergency Response Plan.W/Certificate of Svc ML20058K7841990-06-25025 June 1990 Affidavit of D Albertson.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20058K7941990-06-25025 June 1990 Affidavit of Kj Callahan.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20012C6701990-03-15015 March 1990 Affidavit of Rd Pollard.* Advises That Deficiencies Cited in INPO & Other Repts Demonstrate No Basis for Finding That Reactor Complies W/Nrc Regulations or Can Be Operated Safely ML20012C7121990-03-13013 March 1990 Affidavit of Be Beuchel.* Addresses Intervenors Allegations & Whether Significant Safety Issue Present Re Rosemount Transmitters.Supporting Info,Including Beuchel Prof Qualifications & Certificate of Svc Encl ML20006G1151990-02-26026 February 1990 Affidavit of Gc Minor Re Rev of Rosemount Transmitters at Seabrook.* Discusses Potential Safety Impact of Rosemount Transmitter Problems & Need for Changing Faulty Transmitters Before Plant Proceeds W/Power Ascension & Operation ML20011F1291990-02-16016 February 1990 Affidavit of WT Wallace.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan.Supporting Info Encl ML20011F1281990-02-16016 February 1990 Affidavit of GL Iverson.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan ML19351A7051989-12-0606 December 1989 Affidavit of TC Feigenbaum.* Advises That Further Delay in Obtaining Full Power License for Plant & Reaching Commercial Operations Caused by Further Litigation Will Be Very Costly & Unnecessary.W/Supporting Info & Certificate of Svc ML19332F9701989-11-30030 November 1989 Joint Affidavit of Gc Minor & Sc Sholly.* Opposes Issuance of Full Power OL Until Problems Noted Resolved,Consistent W/ NRC Finding in Confirmatory Action Ltr CAL-RI/89-11.Addl Info & Certificate of Svc Encl ML19332D7011989-11-22022 November 1989 Affidavit of AA Kelsey.* Discusses 1989 Edition of Arbitron Radio County Coverage Rept for Essex County,Ma.Few People in Geographic Area Listen to Whav & Wlyt.W/Certificate of Svc ML20006C4371989-11-21021 November 1989 Affidavit of AA Kelsey.* Discusses Radio Coverage in Merrimac Valley.W/Supporting Info & Certificate of Svc ML19332D5701989-11-17017 November 1989 Joint Affidavit of Gc Minor & Sc Sholly Re New Hampshire Yankee 890921 OL Amend Request (Plant Instrument Air cross-connect to Containment Bldg Air sys,NYN-89116).* Proposed Amend Considered Illogical & W/O Technical Merit ML19332D5301989-11-14014 November 1989 Affidavit of Am Callendrello.* Refutes Intervenors Allegations That Util No Longer Able to Provide Emergency Info to Public as Result of Withdrawal of Agreement Between Util & Wcgy.W/Supporting Info ML19332D5441989-11-14014 November 1989 Affidavit of Gr Gram.* Confirms Util Adherence to 870914 Commitment to Provide Certain Svcs & Equipment for Planning & Implementation of Alerting Sys.W/Supporting Info & Certificate of Svc ML19332D5361989-11-13013 November 1989 Affidavit of Gj Catapano.* Denies Intervenors Allegations That Util Incapable of Providing Prompt Emergency Instructions to Public in Light of Withdrawal of Certain Agreements.Supporting Info Encl ML19354D5121989-11-0909 November 1989 Affidavit of R Boulay Re Voiding of Emergency Broadcast Sys Ltrs of Agreement.* Since Wcgy Voided Ltr of Agreement W/ Util & Withdrew from Emergency Plan,Broadcast Sys for Merrimac Valley Cannot Be Activated.Related Info Encl ML19354D5141989-10-30030 October 1989 Affidavit of R Sawyer Re Voiding of Emergency Broadcast Sys Ltr of Agreement.* Marked-up Affidavit Discussing Impact of Wcgy Voiding Ltr of Agreement W/Util & Withdrawing from Participating in Emergency Planning.W/Certificate of Svc ML19327B7021989-10-27027 October 1989 Affidavit of Jf Bassett Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Fact That Applicant Has Never Followed Through on Commitment to Provide Ebs Equipment,Per 870914 Ltr of Agreement.Supporting Info Encl ML19327B7061989-10-26026 October 1989 Affidavit of Dj Rowe Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Applicant Refusal to Live Up to Commitments to Commonwealth of Ma Ebs.W/ Supporting Info & Certificate of Svc 1999-01-19
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] |
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EXHIBIT 1 SEEIRSVIT QE ESTES Ja JSTISEUS I, Peter J. Matthewu, Rase oath and say es follows:
- 1. .:y naue is Peter J. Matthews.
I am, and sinca January, 1936 have been, dayor of the City of dewburyport, .dassachaaet:L.
- 2. On Septenber 13, 1987 I executed an affidavit in wnic.. I stated that six (6) of the eight (8) emergency notification sirens located in the City of Hewburyport were going to be removad.
l
- 3. Consistent with my prior affidavit, six of the eight amargency notification sirens in the City of Newburyport have ocen dismantled, removed f rom the utility poles on which they were located and are inoperable.
- 4. Two e:aergency notification sirens remain in the City of Cauburyport. They are located on the Neuburyport portion of Plum Island and on Turkey Hill Road in the west end of Newburyport.
The two remaining sirens will ce used only for the City's fire alarm system. Consistent with Newouryport Ordinance 8-17, they will not ce used for Seabrook emergency planning purposes.
3
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eter J. Matthews ' '~
$4 Suoscribed and sworn to before me this day of Novecoer, 1987.
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[ plA /hll]1%N Uotary Puolic My Commission Expires: u . 7, /f9J-h 8801060300 871231 PDR ADOCK 05000443 G PDR
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l EXHIBIT 2 mes aur Board of Selectmen Town Hall, Amesbury, MA 01913 Tel. 388-0290 December 21, 1987 Thomas G. Dignan, Esq.
Ropes & Gray 225 Franklin St.
Boston, MA 02110- -
Dear Mr. Dignan,
On June 29, 1987, during a properly posted meeting of the Amesbury Board of Selectmen, a hearing was held on the validity of permits issued to Public Service Company of New Hampshire for the erection of siren poles and sirens at various locations within the Town. PSNH was represented by Attorney Paul O'Donnell of Ropes & Gray.
The Board of Selectmen voted in the affirmative the following motion offered by Selectman William S. Lord:
That this Board rescind the actions of the Be.srd taken September 4, 1984, when permits for the erection of siren poles were issued; those permits to now be deemed void from date of issue, and the permits be immediately revoked. I further move that Public Service Company of New Hampshire, et al, are ordered to remove the sirens and poles from the Town of Amesbury before midnight of July 13, 1987, and that if not removed by that time and date, the Board take any and all action to cause such removal.
Based on the verbal agreement between Counsel for both parties, the Board has withheld further action pending a decision by the U.S. First Circuit Court of Appeals in PSNH vs. Town of West Newbury (87-1395) .
That decision was handed down on December 16, 1987 in favor of the defendant Town of West Newbury.
The Board of Selectmen is now prepared to carry out the afore-mentioned order of June 29, 1987. The Board once again extends.,to ,
PSNH the opportunity to remove the sirens and poles. The Board orders the removal to be completed by midnight of December 30, 1987. After that deadline the Town will begin to disconnect and remove the sirens )
and poles, j 1
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i mes aur i Board of Selectmen Town Hall, Amesbury, MA 01913 Tel. 388-0290 l
Should the Town of Amesbury be forced to remove these sirens and poles, the Town will assume no responsibility for said equipment.
Furthermore, if the Town is forced to remove the sirens and poles, they will not be released to PSNH until the Town is reimbursed for all costs incurred, including storage.
By, Order of the Board of Selectmen, Robert E. Gaudet, Chairman William S. Lord, Vice-Chairman James N. Thivierge Neil F. Morrissey cc: Attorney General James Shannon Edward Thomas, FEMA West Newbury Selectmen -
Salisbury Selectmen Merrimac Selectmen Newbury Selectmen ,
Newburyport City Solicitor Haverhill City solicitor
~
l ASHOD N. AMIRIAN ATTORNEY AT LAW 376 MAIN STREET, HAVERHILL, MA 01830 TEL. (617) 372 8531 MEMBER OF MASSACHUSETTS 378 1545 AND NEW HAMP8 HIRE BAR December 23, 1987 ATTORNEYGENERACf R W "' m E Il Robert J. Stillman , Esquire C TFC241987 YI E
R0 PES & GRAY 1 225 Franklin Street Nef oston, MA 02110 cc ,.. , f _. -
Department of the Attorney General s Stephen A. Jonas, Deputy Chief Department of the Attorney General John W. McCormack State Office Building One Ashburton Place Boston, MA 02108-1698 Re: Town of Merrimac Gen tl emen ,
I am wri ting in behalf of the Town of Merrimac with regards to the sirens erected by your client, Public Service I am wri ting to you Company of feew Hampshire, in that town.
per your earlier request that all communications regarding the sirens be directed to your firm.
In light of the recent decision of the First Circuit Court of Appeals, the Merrimac Selectmen have decided to remove the siren poles in Merrimac on December 31, 1987 unless your client has removed them prior to that date.
The poles and sirens, if di smantled by the Town, will be stored at the expense of your client if your client declines to remove them or does not take immediate possession of them af ter their removal.
Please let me know what your client's intentio9; are regarding the removal of the poles and sirens as soon as possible.
tru y ours, Ashod N. Amirian Town Counsel ANA:Ph cc: Board of Selectmen
LAGOULIS, CLARK, HILL-WHILTON & MCGUIRE ATTORNEYS AT LAW 01950 * (617) 462 9393 79 ST ATE STREET + NEWBURYPORT, M ASS ACliUSETTS LACOULIS & CLARK, P.C.
R.SCOTTnlLL WillLTON MAURICE G. MCCUIRE JAMES KEVIN BRICitTNEY'
' Admhied Massactmoetts. New HampeNav.
December 17, 1987 J
Robert J. Stillinan, Esq.
Ropes & Grey 225 Franklin Street Boston, IIA 02110 Re: Toun of 11ewbury
Dear !!r. Stillroan:
I am writing on behalf of the' Town of 11ewbury Public with regard Service Company of Ileu to the siretts erected by your client,I am writing to you per your earlier 11ampshir e, in that town.
i request that all communications regarding the sirens be directed to your firm.
l of I f In light of the recent decision of the First Circuit Courtthe tiewbur Appeals, 1987 unless your client has poles in llewbury on December 31, removed them prior to that date.
The poles aind sirelis, if dismantled by the town, will be stored at the expense of your client if your client declines to reiaove )
them or does not take inunediate possession of them af ter their l
removal.
Please let me know uhat your client's intentions are regarding l the removal of the poles and sirens as soon as possible.
Very truly yours,
([ h (L ce
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R. Scott 11111-Whilton RSilli/sml
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AMESBUAY. MASSACHUSC7tS osos 3 ses 76 3ee-3354 December 18, 1987 Robert J. Stillman, Esquire Hopes & Gray 225 Franklin Street Boston, MA 02110 Be n . P.S.N.H. Siren Poles in the Town of Salisbury
Dear Mr. Stillman:
As you are aware, the Town of Salisbury has earlier indicated to you.and your client that it intends to remove the P.S.N.H. siren poles situate on Town property in Salisbury, Massachusetts. By your letter dated May 13, 1987, you.have requested that communication with respect to this matter be directed to you.
This letter is to inform you that I have been directed by the Board of Selectmen to advise that the P.S.N.H. equipment and poles on Town property in Salisbury will be dismantled and renoved' commencing on January 2, 1988, if such equipment and poles are not first removed by your client. If, by your client's inaction in the_ interim, the Town is forced to remove such equipment, the. Town will not assume responsibility for any elamage to the equipment. Moreover, as the Town's storage facilities are extremeJy limited, the equipment and poles may have to be stored at private warehouse facilities in which case your client would be responsible for storage charges and fees upon collecting the poles and equipment.
If you have questions regarding this matter please direct them to me.
cooperation.
Thank you for your attention and anticipated Respectfully, Charles P. Graham CPG:smh cca Board of Selectmen Town of Salisbury
l EXHIBIT 3 1
New Hampshire Yankee Division l
l NHY #870765 December 29, 1987 I
l l
Board of Selectmen Town Hall Friend Street Anesbury, MA 01913 k
Dear Selectmen,
i l
1 As you know, New Hanpshire Yankee Division currently owns and maintains a i public alert notification system in the 'Ibwn of Amesbury.
The public alert notification system was originally installed for use by j Civil Defense officials in the event of an incident at Seabrook Station. As i an additional feature, local public safety officials have the capability to '
activate these sirens for use in a number of potential mergency situations, including natural disasters, hazardous materials incidents, or fires.
(
As a result of recent court actions on siren pole r e oval, New Hampshire Yankee is taking steps to provide alternative methods of notification to Massachusetts residents living within 10 miles of Seabrook Station. i Because we believe that the sirens could continue to provide local civil l.)
defense authorities with an effective means of notifying residents of I emergencies not related to Seabrook, we are extending to the Town of Amesbury {
the following offer. New Hangshire Yankee will give the sirens and poles to i the Town of Amesbury. We will disconnect all equipment used by Seabrook personnel to activate the sirens. We will not be including the Massachusetts siren system in any rh'w=ntation to the Nuclear Regulatory Otmmission or the Federal Dnergency Management Agency involving the licensing of Seabrook Station. )
1 We have stated repeatedly that we wish to be good neighbors. We {
understand that see feel strongly that they wish not to participate in I emergency planning for Seabrook Station. We respect these feelings.
Despite the differences in opinion on Seabrook, m don't believe that -
local residents are well served by the renoval of a . wxisting public alert ;
notification system. We request that our proposal u beluded on the agenda !
of the next meeting of the Board of Selectmen. We would be willing to have a l representative of New Hanpshire Yankee attend the meeting and answer any questions you may have.
l I
l P.O. Box 300. Seabrook, NH 03874 . Telephone (603) 474 9574
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- l. 'j' Please' advise us whether you will be considering our proposal at your upcaning ~ meeting. If we can answer any further questions, please contact Debra Vanderbeek at (603) 474-9521, Ert. 3204. Thank you.for your con-sideration.
Sincerely,
?
hTedVice
/b dlbaum C. Feigen President cc: ASLB Service List Mr. Victor Nerses, Project Manager Project Directorate I-3 Division of Reactor Projects United States Nuclear Regulatory Camission Washington, DC 20555 Mr. William T. Russell Regional A&ninistrator United States Nuclear Regulatory Castission Region I 631 Park Avenue King of Prussia, PA 19406 Mr. Antone C. Corne NRC Senior Resident Inspector Seabrook Station Seabrook, MI 03874.
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EXHIBIT 4 1 ! ? Commonwealth of Massachusetts 5- Executive Office of Environmental Affairs t
Department of Environmental Management Special Use Permit New Hampshire Yankee 100 Cambridge Street Boston Massachusetts Salisbury Beach State Reservation 02202 Salisbury, Massachusetts In conjunction with a policy of land use as stated in Chap-g ter 132A, Sections 2B and 2D of the General Laws of the Commonwealth g gg of Massachusetts, and all other powers enabling:
The Commonwealth of Massachusetts, Department of Environ: mental Management, does hereby grant a Special Use Permit to New Hampshire Yankee (hereinaf ter the Permittee) P.O. Box 300, Seabrook, New Hampshire 03874, as agent for the joint owners of Seabrook Station, to use a certain piece of property located within the Salisbury Beach State Reservation, Salisbury, Massachusetts. (see attached map) The purpose of this authorization being to install and main-tain a public notification siren as part of the emergency planning operation for the Seabrook Station Nuclear Power Plant, Et. 1 Security Building, located in Seabrook, New Eaapshire, 03874 in the case of an accident, as well as a natural disaster or nuclear i
attack. In addition, this siren will also be used as a public address system to notify the public using park facilities in the event of a local emergency.
I In order to protect the rights and safety of the general pub- 1 lic, as well as to insure the reasonable exercise of the permitted !
use, the following conditions and provisions shall prevail: )
- 1. The term of such authorization contained herein shall be for a period of one full year, commencing November 1,1986 and terminating October 31, 1987. tenewal of this pernic shall be the responsibility of the Permittee.
- 2. In consideration for the righte herein granted, Permittee shall pay to the Department the sus of Six Hundred Dollars
($600.00) per year for the term of this authorization.
Payments shall be received by the Department upon the Permittee's acceptance of such authorization. All checks should be made payable to the Commonwealth of Massachusetts, and forwarded to the above address.
Gilbert A. Bliss Direaor
2-
- 3. . Any and all work shall be done under the direct s u pe r-vision of the Regional Forests and Parks Supervisor and/or
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his designee. The Permittee should contact Don Stoddard i Regional Forests and Parks Supervisor prior to servicing
'it s equipment. He may be reached at (617) 369-3350.
- 4. Any and all reasonable requests made by the Regional Forests and Parks Supervisor and or/his designe<_ shall be complied with.
- 5. The Permittee shall be responsible to pay to said Depart-me nt a sum of One Hundred Dollars ($100.00) as an elec-trical power surcharge during the term hereof.
- 6. This permit is not transferable and no privilege contained herein may be sublet to any other person or organization.
- 7. The terms of this permit are not to be construed.as exclusive use of the area by the Permittee.
- 8. The exercise of this permitted' use shall constitute Permittee 's acceptance of complete liability,. for Per-mittee 's own actions while present upon the afore-mentioned site and an agreement that the Permittee will not make any claims against the Commonwealth for any injury, loss, or damage to persons (including bodily injury and death) occurring from any cause arising out of the authorised use of the Permittee, its agents or assigns.
- 9. The Perttittee further agrees to save the Commonwealth harmlesa for any loss or damage that may be incurred to any property and/or equipment owned by the Permittee that will be located upon said site.
- 10. The Permittee shall remove, at its own expense, all of its equipment and apparatus from said site within thirty (30) days af ter final termination of this permit.
- 11. Any interference with radio transmission or reception to the communications systems presently located on this site and any that may be installed in the future by the Depart-ment of Environmental Management, or arising from the presence of this installation shall be immediately cor-rected by the Permittee.
12 The Director of the Division of Forests and Parks may cancel this permit at a9 r time for any reason which in his opinion is in the best interest
, t 3
l I have read the foregoing conditions and provisions approve of, and agree" to these terms.
? 4 , l-s s' Issued Gilbert A. Bliss,' Director Division of Forests and Parks M
Accepted George A. Thomas, Vice President Seabrook Station Public Service of New Hampshire A2 2 H sh
'Appfovpd e Gutensohn, Commissioner Depar ' ment of Environmental Management CAB /JG/j z
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g.
g EXHIBIT 5 Q O I Commonwealth of Massachusetts i*-
~
f Executive Office of Environmental Affairs L MA?'
Department of Environmental Management December 11, 1987 100 Cambridge street Boston Massachusetts 02202 Mr. George S. Thomas Vice President, Nuclear Production New Hampshre Yankee Division Office of the PO Box 300 Commissioner Seabrook, New Hampshire 03874 RE: Removal of Equipment Left at Salisbury Beach State Reservation
Dear Mr. Thomas:
I call your attention to my letter of October 24, 1987, when I informed you that this Department would not renew the permit which allowed you to maintain a public notification siren at the Salisbury Beach State Reservation.
That letter gave you a period up through Monday, Novem-ber 30, 1987 to remove your equipment and property. As of this date. I have been informed that your property is still there.
I will extend to an additional five work days after receipt of this letter to remove New Hampshire Yankee equipment. If it is still in place on Friday, December 18th, employees of this Department will remove and place into storage all equipment.
You may recover it at any time thereafter by paying the cost j of removal and storage. l Lest you believe that the Department has any alternative f course under consideration, you should know by now that your l counsel, Ropes & Gray, were informed in writing on December 1st, 1987 that there is no legal basis for an appeal to my October 24th decision. A copy of this letter will be hand delivered to that firm so that they may give you timely advise as to the impact of this letter.
S cerely you ,
^
Michael S. Dukalus .
Govemor 1-James S. Hoyte Secretary h ames Gutensohn l
- commissioner l
James Gutensohn g Commaaner d cc: Paul J. O'Donnell,lEsq.
Ropes & Gray l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
f.
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3 Commonwealth of Massachusetts k- /'
Executive Office of Environmental Affairs L
Department of Environmental Management Certified #
October 24, 1987 100 Cambridge street Mr. George S. Thomas Boston Vice President, Nuclear Production M ssachusetts New Hampshire Yankee Division 02202 p,o, gox 300 Seabrook, New Hampshire 03874 RE: Special Use Permit - New Hampshire Yankee Office of the Salisbury Beach Stete Reservation Cornmissioner Salisbury, Massachusetts Term: November 1, 1986 - October 31, 1987
(
Dear Mr. Thomas:
The Commonwealth of Massachusetts, Department of Environmental l Management, is in receipt of your letter dated September 10, 1987, !
requesting renewal of the above-referenced Special Use Permit for (
the maintenance of a public notification siren at the Salisbury !
Beach State Reservation. f I am returning to you a check #029939, dated August 31, 1987, in the amount of'S700.00, which accompanied this letter, as this office has opted to exercise its privilege not to renew the permit for another term.
New Hampshire Yankee is authorized to complete the term of its tenancy at the Salisbury Beach State Reservation, which shall remain in effect until October 31, 1987. In accordance with Provision 10 of the above-referenced permit, a copy of which is attached for l your convenience, upon final termination of the permitted use of j the facility, New Hampshire Yankee (Permittee) shall remove all of l its equipment and apparatus from the State Reservation at its own expence, on or before Monday, November 30, 1987.
Thank you for your cooperation garding this matter.
Ve 4 truly yo a gc 2 o"
1 l
J:mes S. Hoyte ec: Don Stoddard, Regional Supers i tor N Mi 4 ,. g3 p . ,
Michse l rMrkW6fi@'Hamp Travia Beird,FNek shije tankeeM i isbury 4lr -
J:mes Gutensohn '
.I, Commastoner JG/jz .
Attachment l
_____________D
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s t=>3\f George S. Thomas
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Pete SerWoe of New 6 New Hampshire Yankee DMelon September 10, 1987 Mr. Gilbert A. Bliss, Director Division of Forest and Parks Department of Environmental Management coussonwealth of Massachusetts 100 Cambridge Street Boston, MA 02202
Dear Mr. Blies:
Enclosed is payment for renewal of the special use permit for the public notification siren located in the Salisbury Beach State Reservation. The payment amount includes $600.00 for the maanal permit fee and $100.00 for the annual electrical surcharge, in accordance with provision #2 and #5 of the permit.
If you should have any questions, please contact Travis N. Beard (603) 474-9521, extension 2750.
Very truly yours, Geo se S. Thomas Enclosure .
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